Health Plan Transactions: Trends and Issues

Manatt, Phelps & Phillips, LLP

Manatt, Phelps & Phillips, LLP

Editor’s Note: The number of healthcare transactions reached a record-smashing 1,738 in 2018.1 According to a new Capital One poll, mergers and acquisitions are the preferred growth vehicle for 44% of healthcare executives in 2019, indicating that we will continue to see M&A on the rise. What are the trends driving the growth in healthcare transactions? What are the new M&A strategies remapping the healthcare landscape? In a recent webinar, Manatt Health shared the answers. In part 1 of our articlesummarizing the webinar, published in our April “Health Update,” we examined the major healthcare trends fueling the changes in healthcare M&A. In part 2, published in May, we shared a deep-dive look at provider transactions. Part 3 of our summary, below, provides an in-depth analysis of health plan transactions. Click here to view the full webinar free, on demand—and here to download a free copy of the presentation.


Trends Driving Health Plan Transactions

There have been a number of health plan transactions over the past year, but we’ve seen a shift in the types of deals. In 2017, health insurers were focused on horizontal integration, but those efforts met regulatory roadblocks due to antitrust concerns. As a result, health plans turned to vertical integration, where antitrust barriers would be less significant. They moved from strategies built on growing their market share only within the insurance sector to strategies that would help them gain control of the delivery system and supply chain that are integral to the insurance business. As a result, we’ve seen growing momentum around insurer-provider joint ventures, though those can face barriers, as well.

Health Plan Consolidation Faces Antitrust Hurdles—but Medicaid Can Present Opportunities (and Challenges)

Health plans seeking to consolidate have faced antitrust hurdles. In January 2017, the proposed Aetna-Humana merger was blocked by the court after the Department of Justice (DOJ) sued to stop the merger. The following month, the proposed Cigna-Anthem merger met a similar fate.

Although the Aetna-CVS merger was not blocked by the DOJ on antitrust grounds, it really is primarily a vertical rather than a horizontal merger. In addition, to move forward, the DOJ required that Aetna divest its Medicare Part D business to WellCare. (Both Aetna and CVS were significant participants in the Medicare Part D market). Therefore, although the merger was not blocked on antitrust grounds, it does support the general principle that there is significant suspicion and scrutiny of any horizontal integration, even when the areas of overlap are just a small component of the full transaction. (On June 4, the Aetna-CVS merger also faced an unprecedented Tunney Act review hearing, with oral arguments scheduled for July 17.)

The one area that may present opportunities for consolidation without raising major antitrust concerns is the Medicaid managed care market. There is less concentration in Medicaid managed care, in part because it’s a state-by-state program—and states differ significantly in their participating plans. For example, in some states, provider-sponsored plans play a major role, while in others large national insurers dominate. As a result, Medicaid managed care has a lot more dispersion of market share and, therefore, fewer antitrust barriers than the Medicare and commercial markets.

There are, however, other potential political and regulatory obstacles. A good example is Centene’s $3.75 billion acquisition of Fidelis, announced in September 2017. Fidelis was a large Medicaid managed care plan that had more than 1 million members and was affiliated with the Catholic Church in New York. When the transaction was announced, there were no regulatory barriers, as long as the proceeds from the deal went to a charitable foundation, because Fidelis was a tax-exempt health plan.

Shortly after the deal was announced, faced with budget pressures, the Governor of New York introduced a proposal for a “public asset fund” that would effectively capture 80% of the Fidelis transaction proceeds. The following month, there was another legislative proposal advanced that would allow the state to claw back the “excess reserves” of not-for-profit Medicaid plans. Both of those initiatives were triggered by the announcement of the Fidelis-Centene deal—and the state’s interest in securing a portion of transaction money to help close the state’s budget gap.

After an intense lobbying effort and significant negotiation, there was a resolution that allowed Centene to close the deal. Fidelis transferred $3.2 billion to a foundation that was established by the church. The New York State fund received $2 billion, based on the threat of more restrictive legislation.

As the Centene-Fidelis example illustrates, while Medicaid transactions may not face antitrust hurdles, they can be more sensitive from a political standpoint. Centene’s planned $17.3 billion acquisition of WellCare—which it still expects to close in the first half of 2020—is undergoing scrutiny. (After the webinar, on May 22, the company announced that it had received requests for additional information from federal regulators.)

Insurers Pursuing Vertical Integration

Outside of a few limited examples, insurers are largely focusing on vertical integration in lieu of horizontal integration. Insurers have set their sights primarily on three types of organizations:

  • Pharmacy benefit managers (PBMs) and pharmacies, with examples including CVS’s $69 billion acquisition of Aetna, which closed in November 2018, and Express Scripts’ $67 billion merger with Anthem, which closed in December 2018
  • Long-term care providers, with examples including Humana’s acquisitions (through a joint venture with TPG Capital and Welsh Carson) of Kindred at Home for $4.1 billion and Curo (one of the country’s largest hospice providers) for $1.4 billion, with both closing in July 2018
  • Medical groups/independent practice associations (IPAs), with examples including Optum’s $4.9 acquisition of DaVita Medical Group, announced in December 2017 (with the closing still pending at a reduced price of $4.35 billion), as well as Humana’s purchase of a sizable Florida practice, the Family Physicians’ Group, which closed in April 2018

Vertical Integration Gives Health Plans In-Person Touch Points

There is a common thread running through all these deals. Health plans are seeking touch points that enable them to engage with their members and interact with communities. This new level of connection gives them a greater ability both to deliver services and to affect members’ behaviors.

In the CVS-Aetna deal, Aetna now has reach into a vast network of local retail outlets accessible to its members, even those in rural areas. The merger brings the opportunity to refashion stores as healthcare hubs with retail clinics and other services focused on prevention and care management.

The Humana-Kindred deal brings care home to medically-fragile members and uses technologies (such as remote monitoring and telehealth) to enhance the scope of available services. The service offerings are particularly well-suited to Medicare and dual eligible members who may have difficulty accessing care.

The Optum-DaVita Medical Group deal aligns physician incentives with the plan’s quality and cost-effectiveness goals. It also allows Optum to use its physician network as a differentiator that sets it apart from its competitors.

Potential Regulatory Challenges Following Vertical Integration

There are significant regulatory issues involved in bringing payers and providers together under common ownership. It is important to structure the financial relationships between payers and providers carefully to avoid kickback and other fraud and abuse claims.

There also can be concerns around data sharing, so it is critical to ensure compliance with the Health Insurance Portability and Accountability Act (HIPAA) and other privacy laws. Organizations coming together can mistakenly believe that once they are under common ownership, they can function as one entity. The way the HIPAA rules are structured, however, health plans and providers are separate covered entities for purposes of disclosing information. This holds true even if they are affiliated and elect to be treated as a single covered entity. Therefore, combined organizations need to be cautious when considering the kinds of data sharing that are permissible.

In addition, there are business challenges when bringing together payer and provider organizations. Providers are historically focused on fee-for-service billing and volume generation. Their operations typically have to be re-engineered to align with health plan goals around increasing value and controlling utilization. It can be a complicated process to harness the provider’s resources to support the plan’s objectives without alienating the provider’s other customers, such as other insurers with which it does business.

The Elimination of Independent PBMs

The major deals completed in 2018 have resulted in the virtual elimination of the independent PBM model. There are some smaller PBMs, but the big players have been purchased in a series of major deals, including:

  • CVS’s $12 billion acquisition of Caremark in 2006
  • Express Scripts’ $29 billion acquisition of Medco in 2012
  • Optum’s $13 billion acquisition of Catamaran in 2015
  • Aetna’s $69 billion merger with CVS Caremark in 2018
  • Express Scripts’ $67 billion merger into Anthem in 2018

These mergers share a common set of goals, including:

  • Cutting costs through control of the supply chain;
  • Creating insurer access to PBMs;
  • Building more diversified revenue streams;
  • Enhancing access to timely and usable data through both provider portals and insurer portals; and
  • Defending against potential market disruptors, such as Amazon.

Joint Venture Activity: An Alternative to Acquisitions

In the past few years, there has been a renewed interest in insurer-provider joint ventures (JVs), as an alternative to acquisitions. The focus of the JVs varies. For example, the Tufts-Hartford JV in Connecticut is focused on Medicare at this point. In other states, JVs have had more of a commercial focus. In all cases, however, a health system and a health plan are coming together to create a new entity, jointly owned by the two parties.

One of the primary drivers of the growth in JVs is the increasing emphasis on value-based purchasing that triggered the need to align payer and provider interests. The move to full risk sharing then made it an easy leap to joint ownership, since the process of re-engineering the hospital system to align with the insurance-based reimbursement approach had already begun.

From the hospital standpoint, JVs offer a way to capture more of the health plan’s premium dollars. Hospitals also benefit from lower capital requirements and less risk than sole ownership.

For health plans, JVs can be a market differentiator, particularly if they are partnering with a health system that has a strong market position in the local community. By cobranding, the health plan can benefit from the hospital’s good standing and reputation for quality.

Finally, JVs offer the opportunity to use reinsurance for risk sharing in Medicare Advantage. In prior years, a hospital might start a plan and then look for reinsurance from a health insurer willing to share some of the risk. With CMS now taking the position that quota share reinsurance is not permissible in Medicare Advantage, that model is blocked, making joint ownership more attractive.

Risks and Challenges of JVs

One of the major obstacles to a successful payer-provider JV is the potential resistance within hospital systems to thinking like insurers rather than providers when delivering care. There has to be a culture change within the hospital, and that can be a difficult transition. The 50/50 governance model can lead to deadlock, if health system executives can’t start viewing themselves as being part of a health insurance company.

If hospitals and doctors are exclusive to the health plan, there also could be potential antitrust issues raised. It is important to consider if the joint venture’s market share is significant enough to raise antitrust concerns. It is also critical that financial arrangements between the partner organizations are managed to avoid any possible kickback liability.

Finally, the greatest challenge, particularly in the Medicare Advantage area, could be in risk adjustment coding. Hospital ownership of an insurer is likely to heighten scrutiny of risk adjustment coding practices.

Due Diligence Issues in Health Plan Transactions

There are several key due diligence issues to consider when health plans are entering into horizontal transactions. It is important to be sure that the buyer has the licenses and government contracts necessary to operate in all relevant service areas. Transactions involving Medicare can pose added challenges, particularly if there is an attempt to sell part of the Medicare business, since CMS has a “partial novation” restriction on Medicare Advantage plans. As a result, there often may need to be restructuring to deal with Medicare issues.

When conducting due diligence for a horizontal transaction, it is also critical to consider if the potential partner has any False Claims Act or other regulatory liabilities, such as pending subpoenas or Civil Investigative Demands (CIDs), as well as any current audits, self-disclosures or hotline complaints. In addition, it is key to assess the assignability of key contracts with providers, as well as with PBMs, IT vendors and other business partners. Finally, those considering the transaction should assess the likely regulatory approval process and potential hurdles from CMS, state insurance and Medicaid agencies, and the DOJ. To be complete, the assessment should include a review of the political landscape and a look ahead at additional regulatory concerns that may be raised when the deal is announced.

1 S&P Capital IQ.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Manatt, Phelps & Phillips, LLP | Attorney Advertising

Written by:

Manatt, Phelps & Phillips, LLP

Manatt, Phelps & Phillips, LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.